Privacy Notice

Privacy Notice

Privacy Notice

The purpose of this Privacy Notice (“Notice”) is to provide users of Starting 11’s Mobile Application with information regarding the Personal Data that Starting 11 (also referred to as “we,” “us,” the “Company” or similar terms) may collect, how Starting 11 uses and safeguards that data, and with whom we may share it. This Notice applies to Starting 11’s Mobile Application and all websites owned and operated by Starting 11. This Notice does not apply to any other websites, and we make no representations as to the privacy practices of other websites that may be linked through our website or Mobile Application.

By using our Mobile Application, visiting our website, or submitting Personal Data to Starting 11 by any other means, you acknowledge your understanding and agreement to the practices described in this Notice, including that Starting 11 may collect, process, transfer, use and disclose Personal Data as described. If you have specific questions or comments regarding the processing of Personal Data, you may contact Starting 11 as provided below.

What Data Do We Collect?

In order to facilitate your participation in our fantasy sports contests of skill, products, services, and promotions (collectively the "Services") as well as allow you to access to our text, images, audio, code and other material they contain or provide (collectively, the “Content”), we collect a variety of information about Mobile Application users and website visitors. This section describes both the Non-Personal Data and Personal Data we collect.

Non-Personal Data.

Each time a computer visits our website or a user opens the Mobile Application, we may collect certain data from that computer or mobile device. This data is automatically collected from the device and may include data such as the following (“Non-Personal Data”):

the type of mobile device or operating system (for example, Android or iPhone)

the type of web browser software the computer used (for example, Google Chrome or Internet Explorer)

the name of the domain from which the device accessed the Internet

the Internet address of the website from which the computer linked directly to the website

the date and time the device accessed the website or Mobile Application

Non-Personal Data does not tell us who you are.

Also, we may place a text file called a cookie in the browser files of computers and devices that visit the website or Mobile Application. Cookies are pieces of data issued by a website that, among other things, allow your computer to utilize all the features on this website. If and when your computer accepts a cookie, the cookie may be stored on the computer’s hard drive. You are always free to decline our cookies if your browser permits, but some parts of the Website may not work properly for you if you do so.

Personal Data.

In the course of using our Services or engaging our Content, you may provide us with information such as your name, birthdate, email address, physical address, geolocation information, information required for tax purposes, or similar information (“Personal Data”).

How Do We Share, Use, and Disclose Data?

The ways we share, use, and protect data depends upon the type of data involved.

Non-Personal Data.

We may use non-personal data to help us make the Mobile Application or website more useful to you and for other users. For example, we may track how many devices visited the Mobile Application or what Content was most popular. We may prepare reports and other materials using Non-Personal Data. We may use Non-Personal Data for any other purpose and may share Non-Personal data with third parties in order to improve the Services and Content.

Personal Data.

If you submit Personal Data, you agree that we may keep a record of the Personal Data. We may keep a record of your Personal Data in order to contact you regarding the Services and Content, and, most importantly, we may keep a record of your Personal Data – specifically, your name, birthdate, physical address, and geolocation information – as required and necessary in order for us to comply with national, state, or local laws and regulations regarding providing the Services to users in your jurisdiction.

We also may use Personal Data to help us in our business, including but not limited to improving the Mobile Application or website or for marketing and product development. We will store your Personal Data for the length of time you have an Account with Starting 11, plus 5 years. We may also retain certain information as required by the law in a particular jurisdiction in which Starting 11 operates.

Also, in compliance with the laws and regulations of the relevant jurisdiction in order to support our relationship with you:

we may share Personal Data with our worldwide affiliates to better understand your business needs and how we can improve our products and services;

we may use third party service providers to assist us in collecting, assembling or processing Personal Data in connection with the Services related to your use of the Mobile Application, such as credit card companies;

we (or a third party on our behalf) may use Personal Data to contact you about a Starting 11 offer in support of your use of our Services or to conduct online surveys to understand better our customers’ needs; and

we may use Personal Data for marketing and promotional activities.

If you choose not to have your Personal Data used to support our customer relationship (especially direct marketing or market research), we will respect your choice. We do not sell your Personal Data to third parties, nor share it with third parties except as set forth in this Notice, and any third-party with whom we share Personal Data will provide the same or equal protection of such data as stated in this Notice.

In addition, where consistent with the laws and regulations of the relevant jurisdiction, Starting 11 may disclose Personal Data if such disclosure:

is a use of the Personal Data for an additional purpose that is directly related to the original purpose for which the Personal Data was collected;

is necessary to prepare, negotiate and perform a contract with you;

is required by law or the competent governmental or judicial authorities;

is necessary to establish or preserve a legal claim or defense;

is necessary to comply with a law, regulation, court order, or other legal process;

is part of a corporate restructuring, sale of assets, merger or divestiture;

is required to protect Starting 11’s rights or property, or

is necessary to prevent fraud or other illegal activities, such as willful attacks on Starting 11’s information technology systems.

Email and Link Information.

Using an email address you provide us, we may send you email newsletters or similar documents from time to time. These emails may include technology that permits us to track if and when an email has been opened, as well as whether the recipient clicked on any particular link or advertisement contained in the email. This information is tracked and used for statistical analysis and to help us operate our business. The information gathered from these emails may result in a call or email from our staff to provide further information on Services or Content that our emails have identified you as having an interest in.

California Residents only - Disclosures to Direct Marketing Entities.

This notice applies only to California residents and is made pursuant to California Civil Code § 1798.83. As noted above, we may disclose Personal Data about you, such as your email address, to third parties. If we disclose Personal Data about you to a third party and the third party will use that information for direct marketing purposes, you have the right to contact us at info@starting11.io to request that we notify you as to: (1) what categories of Personal Data we shared with the direct marketer; and (2) the name of the direct marketing businesses with whom we shared such information.

Data Privacy Rights for EU Citizens

Data Access, Correction, and Deletion for EU Citizens

If you are a citizen of the European Union, the General Data Protection Regulation grants you certain rights under the law. In particular, the right to access, correct, or delete the Personal Data Starting 11 holds about you.

Upon request, Starting 11 will grant individuals reasonable access to Personal Data that it holds about them. In addition, Starting 11 will take reasonable steps to permit individuals to correct, amend, or delete information it holds about them. Starting 11 also relies upon each individual to assist in providing accurate updates of his or her Personal Data. In order to access, correct, amend, or delete the Personal Data Starting 11 holds about an individual, the individual should contact the following:

Starting 11 is based in the United States. By consenting to this Notice, you consent to the transfer of your Personal Data to the United States and acknowledge the risks associated with the processing and transfer as described in this Notice.

Starting 11 is Controller:

Under GDPR, Starting 11 is the Controller of Personal Data, the contact information for Starting 11 is as follows:

Mr. Teague Orgeman

3109 W. 50th St., Suite 228

Minneapolis, MN 55410

info@starting11.io

+1 (612) 547-9337

Legal Basis for Processing Under GDPR:

Staring 11 processes your Personal Data based on the consent provided by you when singing up for an Account with Starting 11.

Complaints to the Data Protection Authorities

Individuals may submit a complaint regarding the processing of their personal data to the EU data protection authorities (DPAs). The following link may assist you in finding the appropriate DPA: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

What Happens if the Privacy Notice Changes?

We may change this Privacy Notice at any time and for any reason. If we change this Privacy Notice we will post the change on this section of the Website.

Are There Special Rules About Children's Privacy?

This Website is designed for an adult audience only, and anyone under 18 years old must not use this Website. We will not intentionally collect online any Personal Data (such as a child’s name or e-mail address) from children under the age of 13. If you think that we have collected Personal Data from a child under the age of 13, please contact us as described below.

Security

Your information is stored on servers located in the United States. We and our agents who help us with hosting and security use a number of procedural and technical safeguards to protect your Personal Data against loss or theft as well as unauthorized access and disclosure, including use of encryption, "firewalls," and Secure Socket Layers. If you have specific questions about the Security of systems used by Starting 11, you can contact us as indicated below.

Password and Account Security

If you have an account through the Mobile Application or website, you are responsible for (i) keeping your account password confidential and secured, (ii) restricting access to your computer or Mobile Device and (iii) keeping the e-mail address associated with that account current. You accept full responsibility for all activities that occur within your account and/or using your password.

Links to Other Websites

The website and Mobile Application may contain links to other websites. We provide these links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. We are not responsible for the performance of these sites or for your business dealings with them. Your use of other websites is subject to the terms and conditions of those websites, including the privacy policies of those websites. The appearance of the links does not imply Starting 11's endorsement of the material on any other website and Starting 11 disclaims all liability with regard to your access to or use of such linked websites.

Advertising

This Site may include advertisements for products or services offered by other companies. Starting 11 may receive payment from these advertisers. Although Starting 11 believes you may find the information offered by advertisers to be helpful, Starting 11 does not endorse or guarantee any product or service offered by advertisers.

Contact Starting 11:

If you have any questions regarding this Privacy Notice, you may contact us at: